Comment on Draft Guidance Regarding Use of an Alternate Name for Potassium Chloride in Food Labeling (Docket No. FDA-2019-D-0892)

The National Center for Health Research supports the name “potassium salt” in the ingredient statement as an alternative to the name “potassium chloride.” The name “potassium salt” would be more understandable to consumers and manufacturers, thereby facilitating sodium reductions in processed foods and improving public health. We strongly urge the FDA to amend the draft guidance to permit manufacturers to use the name “potassium salt” as a common or usual name for “potassium chloride.”

In a nationally-representative survey of 1,000 consumers conducted in June 2019, more consumers reported having heard of “potassium salt” being used as a food ingredient than “potassium chloride salt.”[1] Should the FDA permit the term “potassium salt” in place of potassium chloride on ingredient labels, the action would increase consumer awareness of this term and increase its acceptance as the common or usual name of potassium chloride.

Consumers are not likely to confuse “potassium salt” with sodium chloride or other potassium-containing salts. Just as the FDA allows cornstarch to be called “starch” because it is the most widely recognized ingredient in a class of ingredients (starches), it should allow potassium chloride to be used as the most widely recognized ingredient in its class (potassium salts). Since all other salts of potassium would still bear their own distinctive chemical names, consumers would be unlikely to confuse them with potassium chloride if labeled “potassium salt.” Consumers would not confuse “potassium salt” with “salt,” as it is readily distinguishable by the word “potassium.”

Sincerely,

National Center for Health Research

Reference

International Food Information Council. Survey of American adults on familiarity, perceptions, and attitudes around the use of alternative names for potassium chloride in food labeling. June 2019. https://foodinsight.org/kcl-research/

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